Oversight of Intelligence Agencies: A Comparison of the ‘Five Eyes’ Nations

There will always be a tension in democratic societies between the need for intelligence agencies to operate largely in secret, and the need for those agencies to be held accountable for their actions. The frameworks developed by the five countries considered in this paper represent the compromises reached between these two imperatives.
This research paper highlights the differences in the way that each country has chosen to conduct oversight of the intelligence community. What might work well in one country may not necessarily be consistent with the institutions and norms of another. Instead, the oversight frameworks reflect each nation’s political structure, history, and culture, and therefore differ in some of the particulars. However, each country has developed a framework that includes a system of checks and balances that spans the various branches of government, and which aims to ensure that agencies are accountable for both their administration and expenditure, and the legality and propriety of their activities.
The intelligence communities have evolved to meet new challenges as they arise, and will continue to do so. It will be important for the oversight arrangements to keep pace with such changes, and there may well be lessons that the countries considered in this paper can learn from one another as they each continue to review and strengthen their oversight mechanisms.